These disclosures apply to the Portfolio Lab website at portfoliolab.ai, the Portfolio Lab application, and any related services provided under the Portfolio Lab brand (collectively, the “Service”). Portfolio Lab is a product of alphaAI Capital Management LLC (“alphaAI Capital,” “alphaAI,” or “we”). These disclosures do not apply to alphaAI Capital’s managed portfolio services, which are governed by separate disclosures available at alphaai.capital/legal. These disclosures are subject to change without notice; the effective date above reflects the most recent update.

1. Not Investment Advice

The information provided on the Service is for general informational and educational purposes only and should not be construed as investment, tax, legal, or accounting advice. Nothing on the Service constitutes a recommendation, offer, or solicitation to buy or sell any security, investment strategy, or advisory service. Portfolio Lab is a strategy research and simulation tool. Strategies generated by Portfolio Lab are not personalized investment recommendations and have not been evaluated for suitability with respect to any individual’s financial situation, objectives, or risk tolerance. Any investment decision should be made based on your specific financial situation, objectives, and risk tolerance, and in consultation with qualified professionals. Your use of Portfolio Lab does not create an investment advisory, fiduciary, or client relationship between you and alphaAI.

2. Regulatory Status

Portfolio Lab is a product of alphaAI Capital Management LLC, an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”). SEC registration does not imply a particular level of skill or training and does not constitute an endorsement of the firm by the Commission. alphaAI’s registration as an investment adviser applies to its separately offered managed portfolio services, not to Portfolio Lab. Portfolio Lab is not registered, licensed, authorized, or regulated by any financial regulatory authority outside the United States, and the Service is intended for use in the United States only.

You may verify alphaAI’s registration and review its Form ADV filings on the SEC’s Investment Adviser Public Disclosure (IAPD) website at adviserinfo.sec.gov.

3. AI and Algorithmic Process

Portfolio Lab uses artificial intelligence and machine-learning models as part of a systematic, rules-based strategy generation and simulation process. The AI analyzes a range of inputs, including fundamental, technical, macroeconomic, and alternative data, to generate signals and produce candidate strategies. Strategy outputs are produced through predefined optimization rules within parameters selected by the user.

The terms “AI” and “machine learning” describe a class of statistical models trained on historical data. References on the Service to specific numbers of models, datasets, or years of training history reflect the configuration of our system at the time of publication and may change as our systems evolve. We may add, retrain, retire, or replace models from time to time without notice.

The use of AI does not eliminate investment risk and does not guarantee any particular outcome. In particular:

• Models are trained on historical data and may not perform as expected in market conditions outside of the data on which they were trained
• Models can produce inaccurate signals, fail to recognize material changes in market regimes, or be affected by errors or limitations in input data, code, or underlying assumptions
• AI-generated strategies may execute trades at unfavorable prices, may produce losses in real-world conditions even where simulated results are favorable, and may not reflect the impact of all factors that affect actual trading
• Phrases such as “AI-optimized” and similar terms describe a methodology, not a guarantee of optimal outcomes. Strategies that appear optimal on historical data may not perform optimally going forward

AI is a tool used by alphaAI; it is not a substitute for the firm’s professional judgment or compliance with applicable law. You bear all investment risk associated with any decisions you make based on strategies, signals, or other outputs generated by the Service.

4. No Duty to Update

Content on the Service reflects Portfolio Lab’s views, methodologies, and current intentions as of the date of publication and is subject to change at any time without notice. We have no obligation to update, revise, or correct any information on the Service. Discussions of strategies, optimization approaches, asset selections, risk metrics, or other characteristics are general in nature, represent internal guidelines only, and may be modified, suspended, or abandoned at any time based on market conditions, model updates, regulatory considerations, or other factors.

5. Forward-Looking Statements

The Service may contain forward-looking statements, including statements regarding expected strategies, methodologies, model behavior, or future market conditions. Such statements are based on current assumptions and expectations and are subject to significant risks and uncertainties. Forward-looking statements are not guarantees of future performance or outcomes, and actual results may differ materially from those expressed or implied. We undertake no obligation to update any forward-looking statement.

6. Performance Information

Any references to performance, returns, outcomes, or strategy characteristics on the Service, whether explicit or implied, are provided for illustrative and informational purposes only. Past performance does not guarantee future results. No assurance can be given that any strategy will achieve its objectives or avoid losses. Metrics displayed within Portfolio Lab, including but not limited to returns, Sharpe ratios, drawdowns, and other risk-adjusted measures, are derived from simulated or backtested data unless explicitly stated otherwise. Actual results will vary based on timing, market conditions, fees, taxes, individual circumstances, and other factors.

7. Hypothetical, Simulated, and Backtested Performance

Strategies generated by Portfolio Lab are based on hypothetical, simulated, or backtested results and are not representative of any actual client account. Such results should not be relied upon as indicators of future performance. Backtested and simulated results are inherently limited and:

• Are prepared with the benefit of hindsight
• May rely on assumptions that may not hold in real-world market conditions
• Do not reflect the impact of all market factors, including liquidity constraints, transaction costs, slippage, market impact, taxes, and behavioral considerations
• May reflect strategy parameters, model versions, or asset universes that differ from those in current use

Actual results may differ materially and adversely from any hypothetical, simulated, or backtested results.

8. Paper Portfolio

Portfolio Lab’s Paper Portfolio feature uses Alpaca Securities LLC’s paper trading environment to simulate strategy execution with real market data and virtual money. You acknowledge the following limitations of paper trading:

• No real money is at risk. Paper Portfolio results do not represent actual trading or actual investment outcomes
• Paper trading does not perfectly replicate real trading conditions. Execution slippage, partial fills, liquidity constraints, and market impact are generally not reflected
• Paper Portfolio simulations do not reflect taxes, broker commissions (where applicable), or other costs that would affect a real portfolio
• Strategies that perform well in Paper Portfolio simulations may underperform in real trading
• Paper accounts are not real brokerage accounts and are not eligible for SIPC protection. SIPC protection applies only to real-money accounts at Alpaca Securities LLC opened in connection with alphaAI Capital’s managed portfolio services
• We may modify, suspend, or discontinue the Paper Portfolio feature at any time

9. Community Features

Portfolio Lab may offer community features such as leaderboards, trending assets, popular Builds, and personalized performance insights. These features are powered by aggregated and pseudonymized data from users’ Builds and Paper Portfolios, as described in our Privacy Policy. You acknowledge the following with respect to community features:

• Leaderboards, rankings, and other community metrics are provided for informational and entertainment purposes only and do not constitute investment advice, endorsements, or recommendations
• Top-performing strategies on a leaderboard may not represent prudent investment practices and may involve elevated risk, concentration, or other characteristics not suitable for your circumstances
• Past leaderboard performance does not predict future results, including for the same strategy
• Community metrics may be affected by self-selection, short time horizons, or other factors that limit their reliability
• You are solely responsible for any decisions you make based on community data, rankings, or other users’ strategies

10. Optimization and Strategy Generation

Portfolio Lab generates and optimizes strategies based on objectives selected by the user (such as maximizing risk-adjusted return, minimizing drawdown, or other targets) using historical data. Optimization is based on the assumption that historical relationships will persist into the future; this assumption may not hold. A strategy that is optimal on a historical sample may not be optimal, or even profitable, going forward. Optimization targets and reported metrics are based on simulated results and do not constitute projections, forecasts, or guarantees of future performance.

11. Investment Risk

All investing involves risk, including the possible loss of principal. No strategy, asset allocation, risk management technique, or technology, including any AI or algorithmic process, can guarantee profits or protect against losses in all market conditions. You should carefully consider whether the Service and any strategy generated through it are suitable for you in light of your financial circumstances, investment objectives, risk tolerance, and time horizon.

12. Risks by Asset Type

Depending on your subscription tier and your selections, strategies generated through Portfolio Lab may include standard exchange-traded funds (ETFs), individual equity securities, leveraged or inverse ETFs, or exchange-traded cryptocurrency products. Each type of instrument carries distinct risks:

• Standard ETFs: market risk corresponding to the index or basket they track, tracking error, and fund-level expenses that reduce return
• Individual equity securities: single-issuer risk (the value of the security depends on the performance and circumstances of a single company), liquidity risk, and concentration risk
• Leveraged and inverse ETFs: these products use derivatives and daily rebalancing to deliver a multiple or inverse of an index’s daily performance. Due to compounding effects, returns over periods longer than one day may diverge significantly, and in some cases dramatically, from the multiple or inverse of the underlying index’s return over the same period. These products are designed for short-term trading and are generally not suitable for buy-and-hold investors. Losses can be magnified, including in volatile or sideways markets
• Exchange-traded cryptocurrency products: cryptocurrency markets are highly volatile and subject to rapid and substantial price swings. Cryptocurrency products are also subject to evolving regulatory treatment, custody risk, and risks specific to the underlying cryptocurrency and the structure of the product

13. Subscription Services

Portfolio Lab offers subscription-based access to strategy generation, analytics, and simulation tools. Subscription fees are separate from and independent of any advisory fees charged by alphaAI Capital for managed portfolio services. Payment of a Portfolio Lab subscription does not create an advisory relationship, and Portfolio Lab subscription services do not constitute investment advisory services. Subscription terms, including fees, billing, and cancellation, are described in our Terms of Use.

14. Tax Information

alphaAI is not a certified public accountant or tax adviser, and nothing on the Service constitutes tax advice. Tax treatment of investments depends on individual circumstances, including jurisdiction, filing status, and other personal factors, and is subject to change. Paper Portfolio simulations do not reflect the tax impact of trades that would occur in a real portfolio, including realized gains and losses, wash sale rules, and holding-period considerations. You should consult your own tax professional before making any investment decision.

15. Third-Party Information and Links

Certain information on the Service may be derived from third-party sources believed to be reliable. alphaAI does not guarantee the accuracy, completeness, or timeliness of any such information. Any links to third-party websites are provided for convenience only and do not constitute an endorsement of the content, products, or services offered by those third parties. alphaAI is not responsible for the content of third-party websites or for any losses arising from your use of them.

16. Suitability

Not all strategies available through the Service are suitable for all users. Strategies that use leveraged or inverse instruments, cryptocurrency products, or active hedging carry elevated risks and may not be appropriate for users with limited investment experience, short time horizons, low risk tolerance, or limited financial resources. You should consider your investment objectives, risk tolerance, time horizon, liquidity needs, and overall financial circumstances before generating, simulating, or relying on any strategy through the Service.

17. Business Continuity

alphaAI maintains operational practices designed to address disruptions to the Service. Because Portfolio Lab is a software tool that does not custody real assets, a disruption to Portfolio Lab does not affect any real-money investments. In the event of a disruption or discontinuation of the Service, your access to Portfolio Lab features may be interrupted, modified, or suspended.

18. Form ADV, Verification, and Additional Information

alphaAI’s Form ADV Part 2A brochure and Form CRS contain important additional information about the firm and its managed portfolio services. They are available at alphaai.capital/legal and at adviserinfo.sec.gov. Users who deploy strategies with real money through alphaAI Capital’s managed portfolio services are subject to alphaAI Capital’s investment advisory agreement, disclosures, and applicable regulatory requirements, which are separate from these Portfolio Lab disclosures.

19. Contact

If you have questions about these disclosures, contact us at:

Portfolio Lab by alphaAI Capital Management LLC

Email: support@portfoliolab.ai

Web: https://portfoliolab.ai

‍